Unopposed Motion to Modify 45 Order to Surrender, by Dejane Reaniece Lattany — USA v. Lattany (Dkt. 51, D. Colo.)

Record facts

U.S. District Court for the District of Colorado · No. 1:23-cr-00074-NYW · Doc. 51 · 2023-11-27 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLORADO 
 
CASE NO. 23-cr-00074-NYW 
 
 
 
 
 
 
 
UNITED STATES OF AMERICA, 
 
 
 
Plaintiff, 
 
v. 
 
DEJANE REANIECE LATTANY, 
 
 
 
 
Defendant. 
_____________________________________________________________________________ 
 
MOTION TO MODIFY SURRENDER ORDER  
TO ALLOW FOR COLORADO SURRENDER 
_____________________________________________________________________________ 
COMES NOW, Defendant Dejane Reanice Lattany, by and through Assistant Federal Public 
Defender Josh Lilley, respectfully requests that this Court modify Ms. Lattany’s self-surrender 
order to allow her to surrender in Denver, Colorado. In support, Ms. Lattany would show as 
follows: 
1. Ms. Lattany was charged by information with a single count of wire fraud in violation of 
18 U.S.C. § 1343. Doc. 1.  She was sentenced to 48 months imprisonment and three years of 
supervised release. Doc. 27. 
2. In the Second Amended Voluntary Surrender Order Supplementing Judgment, this Court 
ordered that Ms. Lattany ‘surrender at the FCI Victorville Satellite Camp in Victorville, 
California on November 30, 2023. Doc. 45. This Court also noted that travel would be at Ms. 
Lattany’s expense.  
3. Ms. Lattany is currently grappling with severe financial and familial challenges. As a 
single parent, she has shouldered the financial burden of relocating her family and addressing the 
Case No. 1:23-cr-00074-NYW     Document 51     filed 11/27/23     USDC Colorado     pg 1
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immediate and long term needs of her children while she is incarcerated. This process has 
drained her financial resources, leaving little to spare. Ms. Lattany has spent every available 
dollar attempting to transition her family to their new normal during this difficult time.  
4. This Court has previously acknowledged Ms. Lattany’s financial situation, which has 
only become more serious after moving costs. Docs. 34, 35. Ms. Lattany is unable to afford the 
travel costs necessary to get to Victorville, California.  
5. Undersigned counsel contacted the Federal Bureau of Prisons Designation and Sentence 
Computation Center about the logistics of Ms. Lattany self-surrendering in Colorado, pending 
this Court’s approval. The Bureau of Prisons responded “Your client can surrender to the nearest 
United States Marshals Services Office. The United States Marshals Service is responsible for 
the coordination and transportation of federal prisoners who have been designated to a Bureau of 
Prisons facility.”  Ms. Lattany would self-surrender to the United States Marshals in Denver, 
Colorado. The email correspondence with the Bureau of Prisons has been attached as Exhibit A.  
6. The Government was contacted and does not oppose this request. 
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Wherefore, Ms. Lattany respectfully requests that this Court modify or amend the Voluntary 
Surrender Order, allowing her to self-surrender to the United States Marshals Service in Denver, 
Colorado on November 30, 2023.  
 
Respectfully submitted, 
 
 
 
 
 
 
 
VIRGINIA L. GRADY 
 
 
 
 
 
 
Federal Public Defender 
 
 
 
 
 
 
 
 
/s/ Josh Lilley  
 
 
 
 
 
 
 
 
Josh Lilley 
 
 
 
 
 
 
Assistant Federal Public Defender 
 
 
 
 
 
 
633 17th Street, Suite 1000 
 
 
 
 
 
 
Denver, CO 80202 
 
 
 
 
 
 
Telephone: (303) 294-7002 
 
 
 
 
 
 
FAX: (303) 294-1192 
 
 
 
 
 
 
Email:  josh_lilley@fd.org 
 
 
 
 
 
 
Attorney for Ms. Lattany  
 
 
 
 
 
 
 
 
Case No. 1:23-cr-00074-NYW     Document 51     filed 11/27/23     USDC Colorado     pg 3
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CERTIFICATE OF SERVICE 
 
 
 
 
 
I hereby certify that on November 27, 2023, I electronically filed the foregoing with the 
Clerk of Court using the CM/ECF system which will send notification of such filing to the 
following e-mail addresses: 
 
 
Nicole C. Cassidy, AUSA 
 
Email: Nicole.Cassidy@usdoj.gov 
 
 
Rebecca Susan Weber, AUSA 
 
Email: Rebecca.Weber@usdoj.gov  
 
and I hereby certify that I have mailed or served the document or paper to the following non-
CM/ECF participant in the manner (mail, hand-delivery, etc.) indicated by the non-participant’s 
name: 
 
 
Dejane Reaniece Lattany 
(via Mail) 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
/s/ Josh Lilley  
 
 
 
 
 
 
 
 
Josh Lilley 
 
 
 
 
 
 
Assistant Federal Public Defender 
Case No. 1:23-cr-00074-NYW     Document 51     filed 11/27/23     USDC Colorado     pg 4
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